Labor union SAG-AFTRA says further media consolidation will allow broadcast conglomerates to cut even more jobs, hurting local radio and television newsroom operations.
Of all the filings to flood the FCC during its ongoing broadcast ownership review – over 2,100 in all so far – perhaps none better reflect the opinion of the thousands of broadcast employees that might be negatively affected by further broadcast consolidation.
Radio World has been covering both filings and reply comments — which were due Jan. 16 — including recent entries from the National Association of Broadcasters and musicFirst Coalition and the Future of Music Coalition.
The Screen Actors Guild – American Federal of Television and Radio Artists is the largest labor union representing media artists, including, including more than 160,000 actors, announcers, DJs voiceover artists and program hosts.
The organization is urging the commission to keep its current local radio ownership and local television multiple ownership rules in place. SAG-AFTRA believes the rules remain necessary to serve the public interest and to “advance the agency’s three traditional policy goals of competition, localism and viewpoint diversity.”
Jobs at stake
In its comments filed in December as part of the FCC’s quadrennial review process, SAG-AFTRA wrote that the elimination or relaxation of the broadcast ownership rules also risks detrimental impacts on employment within the broadcast industry, particularly in smaller markets.
It’s something the organization believes has been evident during past periods of media consolidation.
“To achieve the economies of scale the companies claim are necessary, conglomerates often centralize work and content production operations that were once the responsibility of local stations,” the organization told the FCC.
Radio and TV broadcasters are already compressing wages and eliminating jobs, including those once held by SAG-AFTRA members, the organization said.
The union cited data from the Radio Television Digital News Association’s 2025 survey, showing that the median radio news operation has only one full-time news staffer, while the average operation dropped to 3.2 full time staffers, down 0.5 from 2024.
Part-time staffing also declined last year, and the trends are consistent across markets of all sizes, according to SAG-AFTRA.
TV news staffing levels are also dropping, according to the organization. In local TV, news employment has been trending down, with the latest RTDNA/Newhouse survey reporting total full-time local TV news employment of 27,066 in 2024, a 2.9% decline from the prior year, and down 3.3% from the 2021 peak, according to the labor union.
Five Forces test
The current media landscape is highly consolidated with a small number of conglomerates having expansive reach, SAG-AFTRA said in comments to the FCC, leaving little room for competition.
SAG-AFTRA said the FCC’s current ownership rules, therefore, serve a “pro-competitive purpose within the television and radio markets.”
Given the existing scope of consolidation, the union says relaxation of the rules would undoubtedly jeopardize “localism and viewpoint diversity” and could result in job loss and economic harm, particularly in smaller local markets.
SAG-AFTRA proposes the FCC use Michael Porter’s “Five Forces” framework to assess the current ownership rules. Porter is the famed Harvard Business School professor who developed the framework often used to analyze industry competition. The framework examines the five “competitive forces” that shape rivalry and profitability:
- Threat of New Entrants
- Bargaining Power of Buyers
- Bargaining Power of Suppliers
- Threat of Substitutes
- Competitive Rivalry
SAG-AFTRA said the five forces are to be evaluated by first weighing each force separately, then collectively to “judge the overall intensity of competitive pressure.”
The union says Porter’s first force, barriers to entry, is particularly applicable to broadcasting, which depends on the exclusive use of a scarce public resource.
“To address this force, among others, Congress conditioned broadcast licenses on service to the public interest, providing licensees use of the airwaves, but not ownership,” the organization said.
With entry constrained, the union wrote, preserving competition in today’s environment depends on preserving legitimate rivalry among the existing licensees and preventing any one owner from gaining leverage over key “buyer” relationships — such as local advertisers and even viewers — and other market forces.
In addition, it said the current rules also help limit owner’s ability to gain outsized leverage over buyers and over key inputs/suppliers, such as network affiliation relationships and high-value programming.
Further, they reduce the risk that consolidation turns “competition” into nothing more than cost-cutting and centralized decision-making that diminishes investment in genuinely local coverage, the labor union said.
While the threat of substitutes, particularly from digital and online media is very real, the actor’s guild said in the broadcast context it does not automatically replicate the competitive constraints that matter most for the public interest broadcasters are meant to serve.
The guild pointed to a court case — Zimmer Radio of Mid-Missouri v. FCC — as an example of why “grounded, force-by-force competitive analysis should matter in connection with the rulemaking.”
In its decision at the time, the Eighth Circuit accepted that the commission may conclude that non-broadcast competition, standing alone, is insufficient to achieve the public-interest objectives historically associated with broadcasting, the union says.
The court deferred to the FCC’s market definitions where the agency provided a rational explanation, SAG-AFTRA told the commission.
Central to its argument, SAG-AFTRA believes that the current ownership rules remain an important tool for preserving competition.
Notably, they help prevent a small number of companies from accumulating outsized control over the highest-reach local outlets, particularly in markets where the number of stations is inherently limited.
“They help preserve real choices for local advertisers and help ensure communities get meaningful local news by reducing the risk that consolidation turns competition into cost-cutting, centralized decision-making, and less investment in truly local coverage,” the organization wrote.
(You can read SAG-AFTRA’s full comments here.)
SAG-AFTRA’s argument about applying the Five Forces test drew the attention of Connoisseur Media and several other broadcast companies in their own reply comments to the FCC. They believe that the proposed competition test “actually demonstrates that consolidation is necessary in the broadcast radio industry.” You can read their discussion about it in their filing (on page 43 of the PDF, labeled as page 38).
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